Transcript OSHA and Emergency Response

OSHA and Emergency Response
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The Occupational Safety and Health
Administration (OSHA) addresses
responsibilities for employers with regards to
disaster preparedness and response in several
OSHA standards.
The following OSHA standards require
employers to address emergency preparedness
in some way:
OSHA’s Emergency Action Plans
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Emergency Action Plans (29 CFR 1910.38(a))
The OSHA Etool on Emergency Action Plans
can be found here.
1910.38 (a)
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Employer’s requiring some employees to use
portable fire extinguishers and others to evacuate
Employers who must supply portable fire
extinguishers but require their employees to evacuate
only
Employers who require employees to evacuate
during certain emergencies e.g. total area flooding
or, evacuation during a release of a toxic substance
Ref: 1910.120(q)
Specific health standards – 1910.1047
OSHA’s Emergency Action Plans
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Businesses that deal with hazardous
substances (such as Ethylene Oxide ,
Methylenedianiline , or Butadiene ), or that
are subject to the provisions of the Process
Safety Management of Highly Hazardous
Chemicals , Hazardous Waste Operations , or
Grain Handling standards may also need to
develop an emergency action plan in
compliance with 29 CFR 1910.38(a) .
OSHA’s Emergency Action Plans
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Emergency action plans and rescue provisions
can also be found in the standards covering
Permit Required Confined Spaces (29 CFR
1910.146), Fire Brigades (29 CFR 1910.156),
and Hazard Communication (29 CFR
1910.1200).
OSHA’s Directive CPL 02-02-073
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OSHA CPL 02-02-073 was issued April 24,
1998.
This instruction updates enforcement
procedures for compliance officers who need
to conduct inspections of emergency response
operations.
National Response Plan and
OSHA’s Role
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New guidance is provided on how the
HAZWOPER standard may apply to unique
events such as terrorist attacks and addresses
OSHA's role under the National Response
Plan.
This instruction assists other Federal, State,
and local personnel who have responsibilities
under incident command systems and will
assist in emergency response operations.
OSHA’s Role Under HSPD-5
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OSHA's relationship with Homeland Security
Presidential Directive (HSPD-5), including
discussion addressing the National Response
Plan (NRP), the Worker Safety and Health
Support Annex, and the National Incident
Management System (NIMS).
Some Basic OSHA Expectations
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Employee protection is priority # 1
Fully consider the widest range of worst case
scenarios when deciding your emergency
actions
As the employer expects more from its
employees, OSHA expects more of the
employer
Plan, communicate and train --- train,
communicate and plan
So What Constitutes a Workplace
Emergency?
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Webster - an unforeseen combination of
circumstances or the resulting state that calls for
immediate action
An unexpected and uncontrolled event that has
seriously harmed or threatens harm to workers
any potential occurrence such as, but not limited to,
equipment failure, rupture of containers, or failure of
control equipment which could result in an
uncontrolled release of a hazardous chemical into the
workplace
Fundamentals
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29 CFR 1910.36 and 37 (emergency egress)
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Sufficient # for the occupancy
Exit ways and access thereto are unobstructed
Exit ways and access thereto are clearly marked
Exit signs are visible at night
Emergency lighting is supplied when needed
OSHA is the authority having jurisdiction
Fundamentals
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1910.151 requires the availability of
emergency first aid
Requires emergency body and eyes flushing
where contact with corrosives can occur
1910.124 – requires “appropriate first-aid
supplies” when employees work with
dipping and coating chemicals
Designated First Aid Responders
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1910.1030 – addresses protection required
against blood borne pathogens - your
designated and collateral duty first aiders are
covered
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ECP
Training on Universal Precautions and the
standard
HBV vaccinations and post exposure follow-up
Collateral Duty Exception
Personal Protective Equipment
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OSHA Subpart I – 1910.132-138
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Assess your emergency plan to ensure that PPE
needs have been anticipated
Provide the required PPE
Train and re-train employees (as necessary) on its
use, maintenance and limitations
Verify and then certify that training was
completed
Emergency Use Respiratory
Protection
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Written program
Provide a respirator for the worst case anticipated
use
Inspect emergency use respirators monthly
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Inspections must include certification
Date, signature, findings, S/N and any actions taken e.g.
“Tank filled”
Train employees on emergency use
Medically evaluate employees
Broad Scope Emergency Standards
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Employee emergency response plans:
1910.38(a)
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Does your plan include evacuation?
Is it required by a specific OSHA standard?
If so, you must follow this standard
The elements are an excellent starting point for all
evacuation plans
BEFORE the Emergency Occurs
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Plan safe evacuation for the range of anticipated emergencies
Assign roles to execute the plan
Identify the means to report emergencies
Prepare written plan that describes roles and evacuation
procedures
Train employees on the plan and assigned roles
Implement and alarm system per 1910.165
Coordinate with outside responders as necessary
Document your efforts, meeting minutes, training records,
disciplinary actions - employee declinations
During an Emergency
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If your planning and preparation is deficient,
your response certainly will be….
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The larger, more newsworthy the event, the more
likely OSHA will be there
OSHA will normally inspect the management of
both the emergency crisis and its consequence
The more reasonably anticipated the emergency,
the higher the expectation that the employer will
respond appropriately
Broad Scope Standards cont.
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Hazardous Waste Operations & Emergency
Response: 1910.120 (q)
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Applies anywhere an emergency chemical release
can occur
All Haz-Mat responders are covered
Performance Oriented
Prior to the Haz-Mat Emergency
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1910.120(q) requires…
A written plan, available upon request to OSHA that
considers….
Pre-planning and coordination w/outside parties
Identified personnel roles, lines of authority, training
and communication e.g. the ICS system
Training on emergency recognition and prevention
Safe Distances and Refuge
.120(q) continued
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Site security and control
Evacuation Routes and Procedures
Decontamination
Emergency Medical Treatment + First Aid
Critique of Response and Follow-Up
PPE and Emergency Equipment
During a Haz-Mat Emergency
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Based on the hazardous substances and/or
conditions present, the individual in charge of
the ICS shall implement appropriate
emergency operations, and assure that the
personal protective equipment worn is
appropriate for the hazards encountered……
IC can appoint a safety officer to oversee
personnel safety
Emergency Haz-Mat Roles During
an Emergency
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The roles that you decide for your employees determine their
level of involvement and the amount of training
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First responder Awareness – Determines if ER needed and notify
First responder Operations – Protect – Contain - Exclusion Zone
Hazardous Materials Tech. – Control at source + Remediation
Hazardous Materials Specialist –could be the “Safety Officer” –
liaison with outside responders
Incident Commander Level – has Operations Level Training with
authoritative and unilateral decision making ability
Emergencies at Plants Covered by
1910.119
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Focuses on preventing accidental releases.
The employer must establish and implement an emergency
action plan for the entire plant in accordance with the
provisions of 29 CFR 1910.38(a).
The emergency action plan shall include procedures for
handling small releases.
Employers covered under this standard may also be subject to
the hazardous waste and emergency response provisions
contained in 29 CFR 1910.120(a), (p) and (q).
.119 requires the training of on-site contractors.
Site Security
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Assess your liabilities and risks
Identify your soft underbelly and firm it up
The greater the consequence, the greater the
need for security
Develop a security culture – employees and
contractors
Develop a strong working relationship with
local police and first responders
Miscellaneous Emergency Related
Issues
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Confined Spaces – Emergency Rescue
Significant Spills must be reported to the
NRC
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800-424-8802
Must report a fatality or hospitalization of 3
or more employees to OSHA within 8hrs.
Protecting Emergency Responders, Volume 1: Lessons Learned
from Terrorist Attacks
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Protecting Emergency Responders: Lessons Learned
from Terrorist Attacks, sponsored by the National
Institute for Occupational Safety and Health
(NIOSH), summarizes the results of a conference
held in New York City on Dec. 9-11, 2001, and
organized by the RAND Science and Technology
Policy Institute. Participants were emergency
workers from around the country who responded to
the bombing of the Alfred E. Murrah Building in
Oklahoma City, the September 11th attacks on the
World Trade Center and the Pentagon, and the
anthrax incidents that occurred during autumn 2001.
Protecting Emergency Responders, Volume 2: Community Views
of Safety and Health Risks and Personal Protection Needs
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Firefighters, law enforcement officers, and
emergency medical service responders play a critical
role in protecting people and property in the event of
fires, natural and man-made disasters, medical
emergencies, terrorist and other criminal acts, and
numerous other types of emergencies.
The authors examine the hazards that emergency
responders face and the personal protective
technology needed to contend with those hazards.
Protecting Emergency Responders, Volume 3: Safety
Management in Disaster and Terrorism Response
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This study provides recommendations for preparing
for response to such disasters and other large-scale
incidents.
It uses literature review, study interviews with
members of the response community, and
information gathered at the RAND CorporationNational Institute for Occupational Safety and
Health workshop Protecting Emergency Responders:
Safety Management in Major Disaster and Terrorism
Response in Arlington, Va., on February 27, 2003.
Protecting Emergency Responders, Volume 4: Personal
Protective Equipment Guidelines for Structural Collapse Events
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This monograph serves as a technical source for
National Institute for Occupational Safety and
Health (NIOSH) incident commander guidelines for
emergency response immediately following large
structural collapse events.
It characterizes response activities and expected
hazards, and develops guidelines for selecting
appropriate personal protective equipment (PPE).